# Finance Act 2025, Paragraph 1: Introduction and charge

Extent: E+W+S+N.I.

(1) This Part of this Schedule sets out a charge on amounts of qualifying overseas capital of individuals previously subject to the remittance basis.
(2) The charge is to be known as the temporary repatriation facility charge, and is referred to in this Schedule as the “TRF charge”.
(3) Paragraphs 2 to 6 set out when amounts are, or are to be treated, as qualifying overseas capital.
(4) Amounts of qualifying overseas capital of an individual are subject to the TRF charge only if the individual designates them in accordance with this Part of this Schedule.
(5) An individual may only designate qualifying overseas capital if the individual was subject to the remittance basis for at least one tax year (being a tax year before the tax year 2025-26).
(6) An individual designates qualifying overseas capital by making an election (a “designation election”) in a return for the tax year 2025-26, 2026-27 or 2027-28 (see paragraph 8 for further provision about designation elections).
(7) A designation election may only be made in a return if, for the tax year to which the return relates, the individual is UK resident for the purposes of income tax and capital gains tax (see Schedule 45 to FA 2013).
(8) The amount of the TRF charge on qualifying overseas capital designated by an individual is—
(a) in the case of amounts of qualifying overseas capital designated in a return for the tax year 2025-26 or 2026-27, the amount equal to 12% of the amount of that capital, and
(b) in the case of amounts of qualifying overseas capital designated in a return for the tax year 2027-28, the amount equal to 15% of the amount of that capital.
(9) Part 2 of this Schedule sets out exemptions and reliefs from income tax and capital gains tax that apply where amounts of qualifying overseas capital are designated.
(10) Part 3 of this Schedule amends or modifies rules about the remittance of amounts where an individual has designated qualifying overseas capital.
(11) For the purposes of this Part of this Schedule—
(a) an individual is subject to the remittance basis for a tax year—
(i) in relation to the tax years 2008-09 to 2024-25, if any of sections 809B, 809D or 809E of ITA 2007 apply to the individual for that year, or
(ii) in relation to any tax year before 2008-2009, if any income or gains of the individual for that year were subject to the remittance basis (including any income or gains that would have been regarded as arising in the tax year but were not as a result of the application of the remittance basis), and
(b) “return” means a return under section 8 of TMA 1970 (personal return for income tax and capital gains tax), and
(c) references to an election being included in a return include an election being so included as a result of an amendment of the return.

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Source: https://www.legislation.gov.uk/ukpga/2025/8/schedule/10/paragraph/1 (the official version)
Page: https://openlegislation.uk/finance-act-2025/schedule-10/paragraph-1
Contains public sector information licensed under the Open Government Licence v3.0. Source: legislation.gov.uk, The National Archives.